Opinion
24068-22
04-17-2023
ALBERT S.N. HEE & WENDY R. HEE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
Upon due consideration of respondent's Motion for Entry of Order That Undenied Allegations Be Deemed Admitted Pursuant to Rule 37(c), filed April 7, 2023, it is
ORDERED that, on or before May 5, 2023, petitioners shall file a reply, if any, to respondent's Answer as amended. Any such reply shall comply with Rule 37(b) of the Tax Court Rules of Practice and Procedure. The Court advises that respondent's above-referenced Motion will be denied if such a reply is filed as directed. Conversely, the Motion will be granted if such a reply is not filed as directed, thereby deeming admitted for purposes of this case the affirmative allegations set forth in the Answer as amended.